IR 05000237/2020001
| ML20133J811 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/11/2020 |
| From: | Kenneth Riemer NRC/RGN-III/DRP/B1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2020001 | |
| Preceding documents: |
|
| Download: ML20133J811 (34) | |
Text
May 11, 2020
SUBJECT:
DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - INTEGRATED INSPECTION REPORT 05000237/2020001 AND 05000249/2020001
Dear Mr. Hanson:
On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Dresden Nuclear Power Station, Units 2 and 3. On April 8, 2020, the NRC inspectors discussed the results of this inspection with Mr. P. Karaba, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. One Severity Level IV violation without an associated finding is documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Dresden Nuclear Power Station, Units 2 and 3. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Kenneth R. Riemer, Chief Branch 1 Division of Reactor Projects
Docket Nos. 05000237 and 05000249 License Nos. DPR-19 and DPR-25
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000237 and 05000249
License Numbers:
Report Numbers:
05000237/2020001 and 05000249/2020001
Enterprise Identifier: I-2020-001-0045
Licensee:
Exelon Generation Company, LLC
Facility:
Dresden Nuclear Power Station, Units 2 and 3
Location:
Morris, IL
Inspection Dates:
January 01, 2020 to March 31, 2020
Inspectors:
J. Corujo-Sandin, Senior Resident Inspector
G. Edwards, Health Physicist
R. Elliott, Resident Inspector
M. Garza, Emergency Preparedness Inspector
T. Go, Health Physicist
J. Park, Reactor Inspector
C. Phillips, Project Engineer
L. Rodriguez, Reactor Inspector
C. St. Peters, Reactor Engineer
Approved By:
Kenneth R. Riemer, Chief
Branch 1
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Dresden Nuclear Power Station, Units 2 and 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors.
Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Unit 2B Low Pressure Coolant Injection Valve Damaged Due To Inadequate Inspection Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000237/2020001-01 Open/Closed None (NPP)71111.22 A self-revealed Green finding and associated non-cited Violation (NCV) of 10 CFR 50,
Appendix B, Criterion V, was identified on October 23, 2019. During a performance of a surveillance test on October 23, 2019, the 2B low pressure coolant injection (LPCI) pump suction valve 2-1501-5B failed to reopen following closure resulting in the 2B LPCI pump being declared inoperable. The licensee's evaluation of this failure identified that an inspection was performed in 2015 with inadequate inspection guidance that should have identified corrosion of the valve motor limit switch that lead to the failure of the valve.
Failure to Account Instrument Uncertainties Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000237,05000249/2020001-02 Open/Closed None (NPP)71111.22 The inspectors identified a Green finding and associated non-cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion XI, Test Control, when the licensee failed to account for instrument uncertainty in surveillance procedures' acceptance criteria for High Pressure Coolant Injection required flow and Ultimate Heat Sink maximum temperature.
Differential Pressure Indicating Switch Failure in Low Pressure Core Injection Loop Select Logic Cornerstone Significance Cross-Cutting Aspect Report Section Not Applicable NCV 05000249/2020001-03 Open/Closed Not Applicable 71153 A self-revealed Severity Level (SL) IV NCV of Technical Specifications (TS) 3.3.5.1,
Emergency Core Cooling System (ECCS) Instrumentation, was identified when the licensee determined during routine surveillance testing that one of four (4) channels of the recirculation pump high differential pressure function was inoperable for longer than the 24-hour allowed outage time.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000249/2019-001-00 LER 2019-001-00 for Dresden, Unit 3, Degraded Differential Pressure Indicating Switch in the LPCI Loop Select Logic Caused by Water Damage Results in a Condition Prohibited by Technical Specifications 71153 Closed
PLANT STATUS
Unit 2 began the inspection period in a forced outage (D2F59) due to an unexplained increase in unidentified leakage. The unit was returned to full power on January 6, 2020. On January 7, 2020, Unit 2 was down powered to 80 percent for control rod adjustment and was returned to full power on the same day, then remained there for the rest of the inspection period.
Unit 3 began the inspection period at full power and maintained full power throughout the first quarter.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/readingrm/doc-collections/insp-manual/inspection-procedure/index.html.
Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. From January 1 - March 19, 2020, the inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; and observed risk significant activities when warranted. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In the cases where it was determined the objectives and requirements could not be performed remotely, management elected to postpone and reschedule the inspection to a later date.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from expected snowfall and wind gusts on February 12 and 13, 2020
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 2 High Pressure Coolant Injection (HPCI) Post Maintenance on March 5, 2020 (2)2/3 Emergency Diesel Generator (EDG) with 2/3 EDG maintenance window on March 24, 2020
- (3) Unit 3 Standby Liquid Control (SBLC) on March 28, 2020
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 3 Isolation Condenser with Unit 3 HPCI maintenance window system on February 25, 2020
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Fire Zone (FZ) 9.0.A, Unit 2 diesel generator elevation 517 on January 10, 2020
- (2) FZ 7.0.A.1-3 and FZ 8.2.7, Unit 2 battery room elevation 549 on January 22, 2010
- (3) FZ 8.2.8.A, Unit 3 main turbine floor elevation 561' on January 27, 2020
- (4) FZ 11.1.1, Unit 3 southwest corner room elevation 476' on January 27, 2020
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on February 13, 2020
===71111.07T - Heat Sink Performance
Triennial Review (IP Section 03.02) (2 Samples 1 Partial)
The inspectors evaluated heat exchanger/sink performance on the following:
- (1) Unit 3 Diesel Generator Cooling Water Coolers (3-6669-A/B), cooled by the service water system, Section 02.02.b
- (2) Unit 3 HPCI Room Cooler (3-5747), cooled by the service water system, Section 02.02.b (3)
(Partial)
Ultimate Heat Sink, Sections 02.02.d.2 and 02.02.d.6
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
=
- (1) The inspectors observed and evaluated licensed operator performance in the Unit 2 Control Room during forced outage D2F59 restart on January 3, 2020
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated 2020-OBE [out-of-the box evaluation] 03B on January 28, 2020
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Rod block monitor (A2 at risk) on February 26, 2020
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 2 Station Blackout Diesel maintenance window on January 27, 2020
- (2) Unit 3 4 KV Technical Specification Undervoltage and Degraded Voltage Relay Replacement (normally done off-line) on February 11, 2020
- (3) Unit 2 Rod Position Indication System (RPIS) Power Supply Replacement (on-line) on February 24, 2020
- (4) Unit 3 work week risk on February 26, 2020
- (5) Unit 2 work week risk on February 26, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Functionality of station black out diesel generator batteries
- (2) Emergency Diesel Generator Unit 2 and Unit 3 Surveillance Requirement 3.3.8.1.4 possibly missed
- (3) Standby Gas Treatment due to use of chemicals in the turbine building
- (4) Unit 3 HPCI - operability of room cooling system with seam leaks in the room
- (5) Unit 2/3 EDG Operability with elevated Ultimate Heat Sink (UHS) Temperature
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Engineering Change 622852, Revision 2, Containment Cooling Service Water 16" Pipe Replacement - DIV I Line 2-1510-16"-D Pipe Penetration on 517" Elevation of the Turbine Building
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:
- (1) Unit 2 Station Blackout Diesel Generator surveillance run after scheduled maintenance window on January 30, 2020
- (2) Unit 3 HPCI on February 27, 2020
- (3) Containment vent and purge isolation valve on February 28, 2020
- (4) Unit 2 RPIS power supply replacement on February 25, 2019
- (5) Unit 2 EDG on March 11, 2020
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated D2F59 forced outage due to generator hydrogen leak, which began in December 2019 and ended on January 3, 2020
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Unit 2/3 EDG Monthly Surveillance on January 6, 2020
- (3) Unit 2/3 B Isolation Condenser Makeup Pump Quarterly Operability under WO 04982736-01
- (4) Recirculation pump DP indication and setpoint calibration on March 20, 2020
- (5) Electromatic relief valve and Target Rock valve calibration and functional test on March 31, 2020
- (6) Unit 2 HPCI, Core Spray and LPCI Verification systems discharge piping are full of water, WO 05003761-01, WO 0500370-01, and 05003762-01 on February 19, 2020
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) 3A Core Spray In-service Test on February 3, 2020
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the following maintenance and testing of the alert and notification system:
- 2018 Annual Preventive Maintenance
- 2019 Annual Preventive Maintenance
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the Emergency Preparedness Organization
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the maintenance of the emergency preparedness program
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) 2020-Out-of-Box Evolution-03B on January 28,
RADIATION SAFETY
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (1 Sample)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
- (1) Unit-2/3 Standby Gas Treatment System and Control Room Emergency Ventilation System (CREVS) Diagram M-49
Temporary Ventilation Systems (IP Section 03.02) (1 Sample)
The inspectors evaluated the configuration of the following temporary ventilation systems:
- (1) Temporary portable high-efficiency particulate air (HEPA) ventilation unit located in the Unit-3 reactor building 545' shutdown cooling heat exchanger room
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to external dosimetry that is used to assign occupational dose
Internal Dosimetry (IP Section 03.03) (1 Sample)
The inspectors evaluated the following internal dose assessments for actual internal exposures:
- (1) Dose assessment of individuals potentially exposed to airborne radioactivity during the clean up and inspection of Unit 2 steam jet ejector 2-300B valve on November 11, 2019, Doc: DR-02-19-00808
Special Dosimetric Situations (IP Section 03.04) (1 Sample)
The inspectors evaluated the following special dosimetric situations:
- (1) Dose assessment for two declared pregnant workers
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
EP01: Drill/Exercise Performance (IP Section 02.12)===
(1)3rd quarter 2019 through 4th quarter 2019
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (2 Samples)
- (1) Unit 2 1st quarter through 4th quarter 2019
- (2) Unit 3 1st quarter through 4th quarter 2019
EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)
(1)3rd quarter 2019 through 4th quarter 2019
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2 Samples)
- (1) Unit 2 1st quarter through 4th quarter 2019
- (2) Unit 3 1st quarter through 4th quarter 2019
EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)
- (1) 3rd quarter 2019 through 4th quarter 2019
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)
- (1) Unit 2 1st quarter through 4th quarter 2019
- (2) Unit 3 1st quarter through 4th quarter 2019
===71153 - Followup of Events and Notices of Enforcement Discretion
Event Followup (IP Section 03.01)===
- (1) The inspectors evaluated Loss of Power to Non-Power Block Buildings and licensees response on March 12, 2020
Event Report (IP Section 03.02) (1 Sample)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000249/2019-001, Unit 3, Degraded Differential Pressure Indicating Switch in the LPCI Loop Select Logic Caused by Water Damage Results in a Condition Prohibited by Technical Specifications (ADAMS Accession No. ML19325C091). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section
INSPECTION RESULTS
Unit 2B Low Pressure Coolant Injection Valve Damaged Due To Inadequate Inspection Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000237/2020001-01 Open/Closed
None (NPP)71111.22 A self-revealed Green finding and associated non-cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion V, was identified on October 23, 2019. During a performance of a surveillance test on October 23, 2019, the 2B low pressure coolant injection (LPCI) pump suction valve 2-1501-5B failed to reopen following closure resulting in the 2B LPCI pump being declared inoperable. The licensee's evaluation of this failure identified that an inspection was performed in 2015 with inadequate inspection guidance that should have identified corrosion of the valve motor limit switch that lead to the failure of the valve.
Description:
On October 23, 2019, the 2-1501-5B was closed during a surveillance test. The valve limit switch had corroded in position and did not remove the torque switch bypass during valve closure resulting in the actuator over thrusting the valve by 250 percent of the rated actuator thrust limit. The actuator springpack, limit switch, torque switch, motor, and operator bolts were replaced. The valve stem and yoke were inspected and were found to be satisfactory.
Upon closure, the valve could not be reopened and the 2B LPCI pump was declared inoperable.
The licensee's evaluation of the event determined that this valve had experienced historical wetting on top of the actuator due to ground water intrusion from as early as 2006. The ground water leakage was eventually repaired in 2009. In 2010 Exelon operating experience required a review of risk significant components that had experienced wetting from internal leakage. The station identified the 2-1501-5B as a component of interest even though it was not considered a risk significant component. An inspection of the actuator was performed during the next 6-year preventive maintenance window for the valve in 2015.
On March 3, 2015, the licensee competed Work Order (WO) 01216146 which performed a PM inspection on the limit switch and torque switch of 2-1501-5B per MA-AA-723-301, Periodic Inspection of Limitorque Model SMB/SB/SBD-000 Through 5 Motor Operated Valves. During the PM, the limit switch cover and the torque switch were found degraded.
The torque switch and limit switch cover gasket were replaced, and rust found on the limit switch cover was cleaned. Pictures taken during this inspection showed the limit switch rotor base showed signs of corrosion. The corrosion of the limit switch base was not identified, or at least not recorded, during the inspection. The licensee's evaluation stated that the procedure guidence was not clear as to what should have been done about the corrosion on the limit switch base. The inspectors reviewed the licensee's evaluation (which included pictures of the limit switch rotor in 2015) and the 2015 completed work order. Procedure MA-AA-723-301, Step 4.4.5 stated, "inspect limit switch compartment for moisture, corrosion, foreign materials leaking lubricant and casting irregularities. Record inspection results on 2." The inspectors determined that, based on the guidance given in the work order, corrosion found during the inspection was unsatisfactory and should have been addressed either by cleaning or replacement of the limit switch rotor at that time. The licensee's corrective actions were not complete at the time of the inspection.
Corrective Actions: The licensee replaced the actuator springpack, limit switch, torque switch, motor, and operator bolts. The valve stem and yoke were inspected and were found to be satisfactory. The licensee planned to train electrical maintenance personnel on the results of the equipment failure evaluation.
Corrective Action References: Action Request 04290376, 2-1501-5B Valve Failure During DOS 1500-01
Performance Assessment:
Performance Deficiency: The failure to follow procedure MA-AA-723-301, Step 4.4.5, in part, to inspect the limit switch compartment for moisture, corrosion... Record inspection results on Attachment 2, during the inspection of the actuator for 2-1501-5B was a performance deficiency. Valve 2-1501-5B was a safety-related valve and the inspection of the valve actuator was an activity that affected quality. Title 10 CFR Part 50, Appendix B, Criterion V, required that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The maintenance technicians that inspected that valve actuator for corrosion in 2015 failed to identify, document, and correct corrosion that existed on the 2-1501-5B limit switch actuator. This corrosion later resulted in the failure of the valve during surveillance testing. The inspectors determined that this example was similiar to IMC 0612, Appendix E, January 1, 2020, examples 4.c and 4.k.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was screened against the Mitigating Systems cornerstone and determined to be of very low safety significance (Green) because the inspectors answered no all six questions in IMC 0609, Appendix A, Exhibit 2, dated December 13, 2019.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. The cause of this valve failure was greater than three years old and not considered present performance.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and be accomplished in accordance with these procedures. The licensee established MA-AA-723-301, Periodic Inspection of Limitorque Model SMB/SB/SBD-000 Through 5 Motor Operated Valves, Revision 10, as the implementing procedure for WO 01216146, D2 6Y MOV [motor operated valve] Diagnostic Testing & Limitorque Surv [surveillance] 2-1501-5B, an activity affecting quality.
Procedure MA-AA-723-301, Step 4.4.5 states, inspect limit switch compartment for moisture, corrosion, foreign materials leaking lubricant and casting irregularities. Record inspection results on Attachment 2.
Contrary to the above, on March 3, 2015, licensee personnel performed an inspection of the 2-1501-5B LPCI 2B pump suction valve, an activity that affected quality, but did not accomplish the inspection in accordance with procedures that were appropriate to the circumstances. Specifically, licensee personnel failed to follow Step 4.4.5, of procedure MA-AA-723-301 by inspecting the 2-1501-5B limit switch compartment with corrosion present on the limit switch rotor base and did not mark the presence of the corrosion in Attachment 2.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Account Instrument Uncertainties Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000237,05000249/2020001-02 Open/Closed
None (NPP)71111.22 The inspectors identified a Green finding and associated non-cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion XI, Test Control, when the licensee failed to account for instrument uncertainty in surveillance procedures' acceptance criteria for high pressure coolant injection required flow and Ultimate Heat Sink maximum temperature.
Description:
When using an instrument to measure a quantity, the recorded value will always have an amount of uncertainty. These uncertainties need to be accounted for to ensure that when a quality related test is performed the results collected validate the associated SSCs remain withing licensing and design bases values. During their review, the inspectors noted at least two safety-related and Technical Specifications (TS) systems' surveillance tests where the licensee failed to account for said instrument uncertainties. The systems with the deficiencies identified were the high-pressure coolant injection (HPCI) systems and the Ultimate Heat Sink (UHS).
For the HPCI systems, the TS Surveillance Requirement (SR) 3.5.1.6 required the licensee "to verify the HPCI pump can develop a flow rate greater than or equal to 5,000 gpm against a system head corresponding to reactor pressure." The UFSAR Table 6.3-20b described the HPCI LOCA analysis value for the Minimum Rated Flow Over Range as 5,000 gpm. After conversations with the licensee, it was also established that Technical Specifications pump flows were used as inputs into the LOCA analyses without adjustments for uncertainty. This condition was repeated as the licensee transitioned through different nuclear fuel vendors (GE, Westinghouse, and Areva). Procedure DOS 2300-03, "High Pressure Coolant Injection System Operability and Quarterly IST Verification Test," Revision 11, was the implementing procedure to comply with TS SR 3.5.1.6. Step H.5.a and Data Sheet 2 to this procedure established a HPCI flow of equal or greater than 5,000 gpm in order to meet the procedure's acceptance criteria. Flow was measured using Flow Controller FIC 2(3)-2340-1. In licensee's calculation NED-I-EIC-0109, Revision 6, Section 13, "Conclusions", the associated flow instrument uncertainties were determined (these vary depending on the model of the instrument installed and the unit it is installed). The average instrument uncertainty associated with FIC 2(3)-2340-1 was +/- 255 gpm under normal plant conditions and +/- 846 gpm under accident conditions.
For the UHS, the TS Surveillance Requirement 3.7.3.2 required the licensee to verify the average water temperature of the UHS was less than or equal to 95 degrees Fahrenheit (F).
The UFSAR Section 6.2.1.3, Table 6.2-7 and Section 9.5.5 described 95 degrees F as the maximum inlet water temperature for the Diesel Generator Cooling Water and the Containment Cooling Service Water systems. Both of these systems are supplied by the UHS. A sampling review of calculations related to the UHS and supplied systems also noted that 95 degrees F was the maximum UHS supplied water temperature assumed (Reference calculations ATD-0400, "Unit 2/3 Diesel Generator Jacket Water Capacity", Revision 0; and DRE98-0077, "Dresden HPCI Room Thermal Response with Reduced Room Cooler Capability", Revision 001C). Procedure Unit 2(3) Appendix B, "Assist NSO and Common Unit Daily Surveillance Log" Revision 90, was the implemented procedure to comply with TS SR 3.7.3.2. Attachment A to this procedure established an acceptance criteria for the UHS average water temperature of less than or equal to 95 degrees F as measure by instrument TR 2/3-4441-16. The licensee informed the inspectors that instrument TR 2/3-4441-16 had an uncertainty of +/- 1 degree F when measuring temperatures between 90 and 100 degrees F.
Based on the above, the inspectors were concerned that failure to account for said uncertainties could result in a situation where a surveillance test was declared satisfactory when in reality the structure system or component (SSC) could be within the unacceptable results range once uncertainties were considered. Since these were safety-related and TS SSCs a failed TS Surveillance would result in the SSC becoming inoperable and the associated LCO action statement must be entered. A review of the results from the last time the affected surveillances were performed showed results which were satisfactory even when accounting for uncertainties.
In addition, based on the licensee's initial understanding of this issue, the inspectors believed an extent of condition would reveal additional surveillance tests which fail to account for instrument uncertainties. This concern was shared with the licensee. The licensee was evaluating if an extent of condition review was needed.
Corrective Actions: The licensee has validated, currently, there are no challenges to meeting Technical Specifications Surveillance Requirements, and the affected equipment remains operable and able to perform their function. In addition, the licensee was recommending:
1) to revise procedures for HPCI (DOS 2300-03) and UHS (Daily Surveillance Log Appendix B) to account for instrument uncertainty; 2) revise setpoint calculations output listings to designate the associated surveillance procedure; and 3) perform extent of condition review.
Corrective Action References: AR 04315614, NRC Question on DOS 2300-03 Acceptance Criteria AR 04317369, NRC Ultimate Heat Sink (UHS) Inspection Question AR 04318639, NRC UHS Open Question 011-2 AR 04331189, NRC Procedures and Instrument Uncertainty
Performance Assessment:
Performance Deficiency: The licensee surveillance procedures' acceptance criteria for HPCI required flow and UHS maximum temperature failed to account for instrument uncertainty.
This was contrary to Title 10 CFR Part 50, Appendix B, Criterion XI, Test Control, and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, implementing the acceptance criteria as written, without accounting for the associated instruments' uncertainty, could result in a satisfactory test result, when in actuality the SSCs had failed the surveillance test. Since the acceptance criteria values used in the procedure are the same as those used in Technical Specifications and their associated analysis, this would have resulted in the licensee failing to declare the associated equipment inoperable, entering the required TS Limiting Condition of Operation (LCO) action and potentially place the plant in an unanalyzed configuration. This is consistent with the guidance provided in IMC 0612, Appendix E, Example 3.g.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Specifically, the inspectors determined this finding is of very low safety significance (Green) because: the performance deficiency was not a design or qualification issue; it did not represent a loss of the system function; the associated trains were neither inoperable for greater than its allowed outage time nor was it inoperable for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and were not part of an external event mitigating system. The inspector was unable to find an example where the deficient procedures resulted in an actual failed surveillance test.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XI, Test Control, requires, in part, that a test program be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
For high pressure coolant injection, a safety-related SSC:
Procedure DOS 2300-03, "High Pressure Coolant Injection System Operability and Quarterly IST Verification Test," Revision 11, is the implementing procedure to comply with applicable design documents. Section H of this procedure, "Acceptance Criteria", include step H.5.a which states "The HPCI pump develops a flow of greater than or equal to 5000 gpm against a system head corresponding to reactor pressure head with reactor pressure greater than or equal to 920 psig and less than or equal to 1005 psig. (Tech Spec SR 3.5.1.6)."
For the Ultimate Heat Sink, a safety-related SSC:
Procedure Unit 2(3) Appendix B, "Assist NSO and Common Unit Daily Surveillance Log,"
Revision 90, is the implemented procedure to comply with applicable design documents.
A to this procedure was a table which included the established acceptance criteria for the UHS average water temperature of less than or equal to 95 degrees F as required by TS SR 3.7.3.2.
Contrary to the above, as of March 11, 2020, the licensee failed to assure that the testing required to demonstrate that the HPCI and UHS systems would perform satisfactorily in service was identified and performed in accordance with written test procedures which incorporated the requirements and acceptance limits contained in applicable design documents, as evidenced by the following examples:
1) Specifically, for the HPCI systems' procedure DOS 2300-03, Revision 117, the licensee failed to account for instrument uncertainties when establishing the acceptance criteria to ensure successful completion of these tests would ensure the associated SSCs would remain operable and within the acceptable limits as determined by applicable design documents.
2) Specifically, for the UHS system's procedure Appendix B, Revision 90, the licensee failed to account for instrument uncertainties when establishing the acceptance criteria to ensure successful completion of these tests would ensure the associated SSCs would remain operable and within the acceptable limits as determined by applicable design documents.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Differential Pressure Indicating Switch Failure in Low Pressure Coolant Injection Loop Select Logic Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000249/2020001-03 Open/Closed
Not Applicable 71153 A self-revealed Severity Level (SL) IV NCV of Technical Specifications (TS) 3.3.5.1, Emergency Core Cooling System (ECCS) Instrumentation, was identified when the licensee determined during routine surveillance testing that one of four
- (4) channels of the recirculation pump high differential pressure function was inoperable for longer than the 24-hour allowed outage time.
Description:
This LER is associated with a Differential Pressure Indicating Switch (DPIS) failure in the Low Pressure Coolant Injection (LPCI) Loop Select Logic that was inoperable for greater than the TS LCO 3.3.5.1. On September 20, 2019, while performing LPCI reactor recirculating pump A and B Differential Pressure Indication switch channel calibration and channel functional test (DIS 1500-09), it was determined that DPIS 3-0261-35C was inoperable. The licensee entered TS LCO 3.3.5.1 condition C, replaced DPIS 3-0261-35C and restored operability within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Licensee operations staff requested a past operability evaluation of the Unit 3 LPCI Loop selection design function.
On June 20, 2019, water from the Unit 3 East LPCI corner room cooler was leaking (AR 04258407) onto the instrument rack that contained the DPIS 3-0262-35C. The licensee installed a deflector to prevent water from dripping onto the instrument rack. On July 6, 2019, a ground was identified (AR 04262209) on the Unit 3 125 VDC battery. The licensee entered DOP 6900-07 (125 VDC Ground Detection) to try and locate and eliminate the ground. The ground alarm cleared and it was determined that the ground did not affect operability of the 125 VDC system. Two subsequent grounds were identified. The first on July 28, 2019, (AR 04267550) and the second on August 15, 2019, (AR 04272156) on the Unit 3 125 VDC battery system which were determined not to affect the operability of the 125 VDC system.
The 125 VDC battery ground issue was resolved when DPIS 3-0262-35C, which was not qualified for spray or submergence, was replaced on September 20, 2019.
On July 30, 2019, during the reactor recirculation pump running differential pressure switch functional test, the results for all DPISs were satisfactory, therefore it was reasonable to conclude that DPIS 3-0262-35C failed and was inoperable between July 30, 2019, and September 20, 2019. Failure of DPIS 3-0262-35C did not impact the ability of the LPCI system to perform its safety function in the event of an accident. Failure of one DPIS impacts one division of LPCI Loop Select Logic, however the unaffected division remains capable of performing the designed safety function.
Corrective Actions: The DPIS 3-0262-35C was replaced, tested, and the channel of recirculation pump high differential pressure function was restored to an operable status. The licensee performed a past operability evaluation for all DPISs that were used to support LPCI system Loop selection design function and all remained functional with the exception of DPIS 3-0262-35C. The licensee also performed a corrective action program evaluation to identify programmatic factors. Service water was isolated to the Unit 3 East LPCI room cooler until the leak was repaired.
Corrective Action References: AR 04290427, Historical Operability Review for DPIS 3-0261-35C and AR04280928, DPIS Will Not Trip
Performance Assessment:
The NRC determined this violation was not reasonably foreseeable and preventable by the licensee and therefore is not a performance deficiency. The inspectors determined that because the licensee initially took actions to protect the DPIS from the leaking water and successfully completed the surveillance requirement that specifically tested the DPIS post leakage, the failure was not reasonably foreseeable and preventable.
Enforcement:
The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance. Traditional Enforcement is being used because a violation existed, however, there was no performance deficiency. The inspectors used the Interim Guidance for Dispositioning Severity Level IV Violations with No Associated Performance Deficiencies, issued June 15, 2018 (ML18158A220).
Severity: This violation is characterized as a Severity Level IV NCV based on its similarity to SL IV example 6.1.d.1 in the Enforcement Policy.
Violation: Dresden Nuclear Power Station, Unit 3 TS 3.3.5.1, "Emergency Core Cooling System Instrumentation," Condition C requires, in part, that if one or more channels are inoperable, the channel must be restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Contrary to the above, from July 30, 2019, to September 20, 2019, one or more channels associated with TS 3.3.5.1, Condition C, was inoperable and was not restored to an operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Specifically, the 3A reactor recirculation pump DPIS 3-0261-35C was inoperable due to water intrusion on June 20, 2019, which eventually caused the DPIS to fail.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On April 8, 2020, the inspectors presented the integrated inspection results to Mr. P. Karaba, Site Vice President, and other members of the licensee staff.
- On February 28, 2020, the inspectors presented the Radiation Protection inspection results to Mr. P. Boyle, Plant Manager, and other members of the licensee staff.
- On March 12, 2020, the inspectors presented the Triennial Heat Sink inspection results to Mr. P. Boyle, Plant Manager, and other members of the licensee staff.
- On March 27, 2020, the inspectors presented the Emergency Preparedness Program inspection results to Mr. P. Karaba, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
OP-DR-108-111-
1004
Cold Weather Strategy
Corrective Action
Documents
04190166
3-1105-B 3B SBLC Pmp Relief Valve did not Lift at Set Point
10/31/2018
296647
2A SBLC Heat Trace Not Working Properly
11/12/2019
04304584
3B SBLC RV Failed Testing
2/17/2019
04313364
Evaluate Ops SBLC Tank Level Surv Acceptance Criteria
01/28/2020
2693730
2/3-5748-2B Indicating Short
07/18/2016
272885
2/3 B ISO Cond M/U Pump Failed to Start Initially
08/19/2019
4318748
2-1301-607 Has a 1 Drop per 10 Second Packing Leak
2/17/2020
4319355
Fuel Leak on 2/3 B ISO Cond Make Up Pump
2/19/2020
21473
NRC Question
2/25/2020
21772
Loose Handlewheel Found
2/26/2020
Drawings
20600-001
High Pressure Coolant Injection (HPCI) System and
Instrumentation
20700LN001-001
Unit 2 Isolation Condenser System
DOP 1300-M1/E1
Unit 3 Isolation Condenser System Checklist
Miscellaneous
Dresden UFSAR
Procedures
DOP 1100-M1/E1
Unit 3 Standby Liquid Control (SBLC) System Checklist
DOP 1300-M2
Isolation Condenser Makeup Pump Fuel Oil System
DOP 2300-01
High Pressure Coolant Injection (HPCI) System Standby
Operation
DOP 2300-M1/E
Unit 2 HPCI System Checklist
DOP 2300-MI/E1
Unit 2 HPCI System Checklist
DOP 2300-MI/E1
Unit 2 HPCI System Checklist
DOP 6600-01
Diesel Generator 2(3) Preparation for Standby Operation
DOP 6600-E1
Unit 3 Standby Diesel Generator
DOP 6600-E1
Unit 2 Standby Diesel Generator
DOS 1100-02
Standby Liquid Control Tank Heater Surveillance Test
Corrective Action
Documents
290524
Fire Door #67 on 545' Elevation Degraded but Functional
10/23/2019
290768
Fire Door 67 Inoperable
10/24/2019
4318345
Operations 4.0 Critique for Fire Drill (Crew 4, 2-15-2020)
2/15/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Resulting from
Inspection
4309021
U2 EDG Fire Door 17A Inoperable
01/09/2020
4309433
NRC Questions Regarding EDG Fire Doors & U2 DW O2
Analyzer
01/10/2020
4311928
NRC Question Regarding EDG Fire Door Failure Mechanism 01/22/2020
4313138
NRC Identified Issues
01/27/2020
Drawings
2-2350B
Schematic Diagram Diesel Generator 2 Auxiliaries and Start
Relays
Key Diagram Turbine Building 480V Motor Control Centers
28-2 and 29-2
Schematic Diagram Fire Protection Co2 System Part 2
W
M-974
Diagram of Diesel Generator Room Ventilation
L
Fire Plans
117 U3RB-20
Dresden Generation Station Pre-Fire Plan FZ 11.1.1
173 U3TB-84
Dresden Generation Station Pre-Fire Plan FZ 8.2.8A
Miscellaneous
D1620
Kinnear (Division of HARSCO Corporation) Automatic
Closing Atler Doors
000
Gaseous Suppression System B 3.7.k
Procedures
88-4-26
Checklist No. 1; Acceptance Criteria
DFPP 4175-01
DFPS 4145-01
Cardox System Operability Test
Fire Drill Performance
"Sample" - Fire Drill Record
Calculations
87-0870/915
Unit 3 Diesel Cooling Water Pump NPSH, Fuel Oil Line
Pressure Head and Air Start Receiver Valve Pressure
Rating Evaluation
1C
ATD-0400
Unit 2/3 Diesel-Generator Jacket Water Cooler Capacity
0D
ATD-0400
Unit 2/3 Diesel-Generator Jacket Water Cooler Capacity
ATD-0400
Unit 2/3 Diesel-Generator Jacket Water Cooler Capacity
0B
CMED-057604
Evaluation of the Functional Capability of Components
Located in Dresden Unit 3 EQ Zones 4, 5, 6, for Elevated
Temperature due to Loss of Room Coolers
DRE03-0026
Analysis of the Intake Canal, CCSW Heat Exchanger, and
Temporary Pumps Following a Dam Failure and 1 Inch
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
DRE16-0011
Required Ultimate Heat Sink (UHS) Capacity
0A
DRE16-0011
Required Ultimate Heat Sink (UHS) Capacity
DRE98-0077
Dresden HPCI Room Thermal Response With Reduced
Room Cooler Capability
1C
RSA-D-92-06
HPCI Room Thermal Response With Loss of HPCI Room
Cooler at Dresden Station
Corrective Action
Documents
0770694
Enhance Accuracy for Intake Temperature Monitoring
05/01/2008
21725
U3 DGCW Flanges Less Than B16.5 Minimum Thickness
01/26/2010
1084166
DTP 09: Small Steam Leak
06/24/2010
2532555
UHS Insp. - Calc for DGCW Pumps Based at 501 Elevation
07/24/2015
2532734
UHS NRC Insp. - Basis for UHS Vol. (2 Million Gallons)
07/25/2015
2533713
Further Information for IR 02532555
07/28/2015
3949714
U3 HPCI Room Cooler Fan Degraded
2/06/2016
3984974
Unit 3 HPCI Room Cooler Eddy Current Results
03/14/2017
4058405
DTP 09: Small Steam Leak on HPCI Turbine Poppet Valves
10/02/2017
4093842
Small U3 HPCI Room Cooler Leak Identified by NLO on
Rounds
01/16/2018
4109028
HPCI Room Cooler Tube Plugging
2/27/2018
4110057
Unit 3 HPCI Turbine-CV Rack Steam Leak at Flange Mating
Surf.
03/01/2018
204847
Leak Identified During VT-2 Inspection of CREVS Cooling
2/20/2018
206201
Bathymetric Survey Results for 2018
2/27/2018
206210
U2 HPCI Room Cooler Leak Identified
2/27/2018
206439
UFSAR Update Required to Address UHS Related Issue
2/28/2018
27793
Strategic Engineering Review of 2018 UHS Survey Results
03/08/2019
297362
Bolted Connection 20 DPM Leak on 2B LPCI Room Cooler
11/14/2019
4309911
DTP 09 - Steam Leak on HPCI Turbine
01/13/2020
Corrective Action
Documents
Resulting from
Inspection
4316968
U3 Diesel Generator Cooling Water Pump
2/11/2020
4316989
NRC - Scaffolding Left Past due Date Near 3D CCSW Pump
2/11/2020
4317210
NRC Identified Corrosion on SW Elbow in U3 HPCI Room
2/12/2020
4317369
NRC Ultimate Heat Sink (UHS) Inspection Question
2/12/2020
4317374
NRC Question on U3 EDG CWP Motor Cooler Inspection
2/12/2020
4317695
DOS 6600-08 Opportunity to Improve Writers References
2/13/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
4318541
NRC UHS Inspection - Basis for HPCI Operability in UFSAR
2/17/2020
4318639
NRC UHS Open Question 011-2
2/17/2020
4318708
NRC Question of 50.59 Screening
2/17/2020
22212
20 UHS Inspection: DRE16-0011 UFSAR Timely Update
2/28/2020
22375
20 NRC UHS Inspection: UFSAR Revision UHS Volume
2/28/2020
22395
20 UHS Inspection - NRC Calculation Question
2/28/2020
23025
20 UHS Inspection - IR 2533713 Action not Complete
03/02/2020
25402
Timber Mat Contact
03/10/2020
Engineering
Changes
363202
ENGR Review Material Change and EDG Thermal Report
for EDG Heat Exchangers
2082
Licensing Basis of the Ultimate Heat Sink (UHS) and the
Impact of Silting
403120
Computation of DGCW Pumps NPSHA During Dam Failure
29625
Licensing Basis of the Ultimate Heat Sink (UHS) Credited
Volume and UFSAR Update
Engineering
Evaluations
20-02-001
Update to UFSAR Description of the Ultimate Heat Sink
(UHS) Credited Volume
Miscellaneous
218036.00
2018 Bathymetric/Volume Survey of the Intake/UHS Canal
10/25/2018
219026.00
2019 Bathymetric/Volume Survey of the 2/3 Intake/UHS
Canal
10/23/2019
50384
BEM Condition Assessment of 24" Carbon Steel Piping
CCSW Unit 2 - 2-1505-24"
2/03/2019
AH1406-
40656587
Long Range Guided Wave Ultrasonic Pipe Screening
Results
06/18/2019
AH1406-
40656587PIMS
Long Range Guided Wave Ultrasonic Pipe Screening
Results
06/24/2019
EA Project No.
1500411
2017 Bathymetric Survey of the Intake Canal at Exelon
Generation Company's Dresden Generating Station
SL-013900
Field Surveillance Report Annual Lake Monitoring and
Examination of Circulating Water Canals August 2017
SL-014493
Field Surveillance Report Annual Lake Monitoring and
Examination of Circulating Water Canals June 2018
SL-015035
Field Surveillance Report Annual Lake Monitoring and
Examination of Circulating Water Canals June 2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Operability
Evaluations08-005
U3 EDG Cooling Water (DGCW) Heat Exchanger (HX) Flex
Hoses10-006
U3 EDG Jacket Water Inlet Temperature Running Higher
Than Normal
Procedures
DIP 3900-01
Diesel Generator Cooling Water Flow Indicator and Pump
Suction and Discharge Gauge Preparation for In-Service
Testing
DIS 3900-03
Diesel Generator Cooling Water Pump Suction and
Discharge Pressure Indicator Calibration
DOA 0010-01
Dresden Lock and Dam Failure
DOA 0010-01
Dresden Lock and Dam Failure
DOA 0010-S1
Key Phone Numbers for DOA 0010 Block Procedures
DOS 0010-01
Dresden Dam Failure Equipment Test
DOS 6600-08
Diesel Generator Cooling Water Pump Quarterly and
Comprehensive/Preservice Test for Operational Readiness
and In-Service Test (IST) Program
System and Equipment Health Monitoring
Service Water Heat Exchanger Inspection Guide
Screening and Evaluation of Potential Aging Issues
Work Orders
01102337
D3 2Y PM Standby Diesel Generator Inspection
01/27/2010
01545660
D3 6Y PM Standby Diesel Generator Inspection
2/23/2018
01592255
D3 8Y PM Replace HPCI Room Cooler Cooling Coil
05/03/2019
01640181
D3 2Y TS D/G CLG WTR PMP Comprehensive Test for IST
Program
07/29/2015
01709946
D3 6Y PM D/G Conduct Eddy Current Test 3-6669-A
2/26/2016
01709947
D3 6Y PM D/G Conduct Eddy Current Test 3-6669-B
2/26/2016
01711473
D3 2Y PM Standby Diesel Generator Inspection
2/25/2016
01711473(SUP)
Supplemental - 00006645-10, PMSR, D3 2Y PM Standby
Diesel Generator Inspection, E: 3-6601, DGNA, E15
2/22/2016
01837703
D3 4Y PM D/G CLG WTR Pump Press. Gauge CAL
09/18/2019
04706728
D3 2Y TS D/G CLG WTR PMP Comprehensive Test for IST
Program
09/16/2019
04797971
U3 HPCI Room Cooler Degrading
05/03/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
04799354
D3 AN COM Inspections of Buried Piping
05/29/2019
04799356
D2/3 AN COM Inspections of Buried Piping
05/29/2019
04870742
D1/2/3 AN PM River Temp Recorder Cal.
01/09/2020
04962726
D3 QTR TS (IST) EDG CLG WTR PMP Test for IST
Program Surviel.
2/19/2019
207934
D3 6Y PM Standby Diesel Generator Inspection
11/13/2006
71111.11Q Miscellaneous
20-OBE-03B
Jan 2020
Corrective Action
Documents
23125
U3 RBM 7 Iprm Input Downscale Trip Ref out of Tolerance
03/02/2020
Miscellaneous
Maintenance Rule
System Basis
Document
Dresden, Unit 3, Rod Block Monitor (RBM)
2/26/2020
Maintenance Rule
System Basis
Document
Dresden, Unit 3, Reactor Protection System (RPS)
2/26/2020
MR Function
Evaluation
Dresden, Unit 3, Reactor Protection System
01/03/2020
MR Function
Evaluation
Dresden, Unit 3, U3 0708-2-N
01/03/2020
Procedures
Inspection
Procedure
Maintenance Effectiveness
01/01/2020
Corrective Action
Documents
4318369
Momentary Loss of Half the Core RPIS Indications
2/16/2020
Drawings
Turbine Building Closed Cooling Water (TBCCW)
Miscellaneous
Protected Equipment Lists for Unit 2 and Unit 3 Risk
Significant Systems
On-Line Risk Management
Protected Equipment List - ADS
2/23/2020
Procedures
DOP 6400-13
Electrical Yard Switching
DOP 6400-13
Electrical Yard Switching
DOS 1100-04
Standby Liquid Control System Quarterly/Comprehensive
Pump Test for the Inservice Test (IST) Program
DOS 1100-04
Standby Liquid Control System Quaterly/Comprehensive
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Pump Test for the Inservice Testing (IST) Program
DOS 5750-04
Control Room Train B HVAC and Air Filtration Unit
Surveillance
DOS 5750-04
Control Room Train B HVAC and Air Filtration Unit
Surveillance
MA-DR-771-403
Unit 3 - 4 KV Tech Spec Undervoltage and Degraded
Voltage Relay Routines
Protected Equipment Program
Work Orders
04982736-01
D2/3 Qtr Com 'B' Iso Cond Make-up Pump Operability
2/19/2020
050008840
IMD TS&R RPIS Power Supply (PSX6)
2/17/2020
Calculations
ATD-0400
Unit 2/3 DG Jacket Water Cooler Capacity
ATD-0400
Unit 2/3 Diesel Generator Jacket Water Cooler Capacity
000A
Calibration
Records
27-1-B33-1
Relay Routine for 4 KV Buss 33-1 Undervoltage Relays
2/10/2020
27-2-B33-1
Relay Routine for 4 KV Buss 33-1 Undervoltage Relays
2/10/2020
Corrective Action
Documents
347338
DG Ventilation Calculation Weaknesses
06/24/2005
4162726
High Vibes on U3 HPCI Room Cooler
08/08/2018
244414
Unexptected Alarm 903-4 C-22 Due to 3-2301 Opening
04/29/2019
262603
IEMA Question Related to IR 4244414 3-2301-14 Valve
Opening
07/08/2019
4312803
Integrated Risk Mitigation
01/26/2020
4315913
NRC Question Regarding DOP 7500-01 Limitations and
Actions
2/06/2020
4315913
NRC Question Regarding DOP 7500-01 Limitations and
Actions
2/06/2020
4316185
NRC SRI Question on Procedural Guidance
2/07/2020
4316185
NRC SRI Question on Procedural Guidance
2/07/2020
4316185-02
NRC SRI Question on Procerdural Guidance
2/25/2020
4316326
Review of STI-16-011
2/08/2020
Corrective Action
Documents
Resulting from
Inspection
04329174
NRC DOP 7500-01 Limitations
03/24/2020
Drawings
Schematic Diagram High Pressure Coolant Injection
Auxiliary Valves
X
Wiring Diagram Reactor Building 250V DC Motor Control
Center 3 Part 1 (3-83250-3B)
V
13524-DGI-N102
Environmental Zone Map (Basement Floor Plan) Elev.
476'6" Figure 1
CCSW Subsystem 1
M-374
Diagram of High Pressure Coolant Injection Piping
CX
Miscellaneous
Dresden UFAR
Operations Log
01/22/2020 -
01/29/2020
Design
Engineering
0006216498
Dresden Unit 2, HPCI Room Cooler Operability System
Code 1500, 2300, 3900
07/07/2000
Dresden Internal
Flood Evaluation
Summary and
Notebook
Table 3.3.1 Isolation of Standby Systems
Letter from
Commonwealth
Edison to A.
Giambusso, U.S.
Atomic Energy
Commissioin
Dresden Station Units 2 and 3 - Special Report No. 37 -
Analysis of Pipe Breaks Outside Containment - AEC
Dockets 50-237 and 50-249
01/23/1974
Procedures
DES 8300-14
Security UPS, Computer UPS, Lake Lift Station, Unit 1,
HCVS SBO 125VDC, 345KV Switchyard, 138KV Switchyard
and 34.5KV Switchyard Batteries Maintenance
DIS 2300-06
Unit 3 HPCI Room Temperature Switch Layout
DOP 1500-02
Torus Water Cooling Mode of Low Pressure Coolant
Injection System
DOP 1500-02
LPCI/CCSW Operation During Transient Situations
DOP 6600-05
Diesel Generator 2/3 Startup
DOP-1500-03
Containment Spray Cooling Mode of Low Pressure Coolant
Injection System
DOS 8300-14
Non-Safety Related 125 VDC and 250 VDC Battery
Surveillance
Surveillance Test Interval (STI) Change Request
DRE-16-011
Dedicated Operator - Proprietary
Corrective Action
Documents
4313545
Air Leak on 2A SBO Eng Start Air LB Supply AOV Iso Vlv
01/29/2020
4313609
U2 SBO 'A' Engine Low Oil Temp
01/29/2020
4313832
U2 SBO D/G Lube Oil Temp Proc Enhancement to DOP
20-16
01/30/2020
4313837
Ops U2 SBO 'A' Diesel Low Jacket Water and Lube Oil T/S
01/30/2020
Drawings
Schematic Diagram Engine A/B 125V DC Starting/Auxiliary
Equipment Station Blackout
A
20600-001
High Pressure Coolant Injection (HPCI) System and
Instrumentation
M-4308A
Diesel Generator Starting Air Piping and Instrument Diagram
Station Blackout
B
Miscellaneous
Operations Log
01/29/2020
Dresden 7 Day Schedule
01/27/2020
Procedures
DOS 2300-03
Initial HPCI Standby Lineup
117
DOS 2300-03
High Pressure Coolant Injection System Operability and
Quarterly IST Verification Test
117
DOS 6600-01
Diesel Generator Surveillance Tests
143
DOS 6600-08
Diesel Generator Cooling Water Pump Quarterly and
Comprehensive/Preservice Test for Operation Readiness
and In-Service Test (IST) Program
DOS 6620-07
SBO 2 (3) Diesel Generator Surveillance Tests
DOS 6620-07
SBO 2(3) Diesel Generator Surveillance Tests
Administrative Requirements for Inservice Testing
MA-DR-MM-5-
66001
Diesel Generator Post Maintenance Testing Run
Work Orders
01002305
D2 12Y PM Diesel Cooling Water Pump Motor Replacement
2/03/2020
01573090
D2 8Y EQ Replace ASCO SOL on DW Purge Valve 1601-56
01/21/2020
04774873
D2 AN COM Replacement Air Start Regulating Valve on
2/03/2020
04829226
Proactive Replacement of U2 EDG Potential Transformer
03/10/2020
04987753
Proactive Replacement of 2-6699-114 Swing Check Valve
03/10/2020
Work Orders
05001931
D3 QTR TS (IST) HPCI Pump Operability Test and IST
Surveillance
2/07/2020
05008145
D2 1M TS (IST) Unit Diesel Generator Operability
03/01/2020
Corrective Action
Documents
4308111
DOA 6100-01 Entry for TR2 Cooling
01/05/2020
4308854
4.0 Critique for D2F59 Startup
01/05/2020
Procedures
DOA 5600-01
DOA 6100-01
Main Transformer Trouble
DOS 1600-10
Drywell Closeout Inspection Plan
Start-Up Checklist
Calculations
NED-I-EIC-0109
HPCI Pump Discharge Flow Loop Accuracy and Minimum
Flow Setpoints Essential Calc
NED-I-EIC-0109
Instrument Uncertainty Calculation for FIC-2(3)-2340-I
Corrective Action
Documents
290376-09
2-1501-5B Valve Failure During DOS 1500-01
2/12/2019
4310164
4.0 Critique U3 HPCI Fast Start Surveillance
01/13/2020
4319355
Fuel Leak on 2/3 B ISO Cond Makeup Pump
2/19/2020
Drawings
M-4203
Flow Diagram Isolation Condenser Make Up System
G
Procedures
DIS 0202-05
Recirc Pump dP Indication and Setpoint Calibration
DOS 1300-03
2/3A(B) Isolation Condenser Makeup Pump Quarterly
Operability
DOS 2300-03
High Pressure Coolant Injection System Operability and
Quarterly IST Verification Test
117
DOS 2300-07
High Pressure Coolant Injection Fast Initiation Test
Unit 2(3)
Appendix B
Assist NSO and Common Unit Daily Surveillance Log
Work Orders
216146
D2 6Y MOV [Motor Operated Valve] Diagnostic Testing &
Limitorque Surv [Surveillance] 2-1501-5B, an Activity
Affecting Quality.
03/03/2015
04795477
D3 8Y PM Recirc Pump DP Indication & Setpoint Cal
03/20/2020
04966573-01
OP D3 QTR TS HPCI Pump Oper Test and IST Surv
01/13/2020
04966573-01
D3 Qtr TS (IST) HPCI Pump Oper Test and IST Surv
01/13/2020
Work Orders
04983344-01
D3 QTR [quarterly] TS [Technical Specification] CS [Core
Spray] Pump Test with Torus Available for IST [In-Service
Test] Data Surv [Surveillance]
2/03/2020
04985748-01
D2/3 1 M TS Unit Diesel Generator Operability
01/06/2020
Corrective Action
04116367
EP-Siren Failure (DR02)
03/19/2018
Documents
04145905
EP-Siren Failure (BD10)
06/11/2018
04154129
Siren Failures (DR01, DR06)
07/09/2018
04167408
EP-Siren Failure (BD02)
08/27/2018
208595
EP-Siren Failure (DR27)
01/07/2019
223376
EP-Siren Failure (DR09)
2/25/2019
229307
EP-Siren Failure (BD18)
03/14/2019
269606
EP-Siren Failure (BD05)
08/05/2019
292284
Inadvertent Siren Activation Of Will County Sirens
10/29/2019
294339
EP-Siren Failure (DR01)
11/04/2019
295174
EP-Will County Siren Controller Failure
11/05/2019
04300920
EP-Siren Failure BD11
2/02/2019
04309736
EP-Siren Failure (DR15,DR22)
2/20/2020
Miscellaneous
Braidwood/Dresden 2018 Warning System Maintenance and
Operational Reports
Braidwood/Dresden 2019 Warning System Maintenance and
Operational Reports
Dresden Generating Station Alert and Notification System
(ANS) Design Report
Corrective Action
Documents
04176439
EP. Drive-In Drill / Off Hours Drill Program Administration
09/24/2018
04176441
EP. Drive-In Drill / Off Hours Drill Facilities and Equipment
09/24/2018
04176442
EP. Drive-In Drill / Off Hours Drill Combined FAC
Comments
09/24/2018
04198974
Individual's ERO FMT Qualification Expiring
11/29/2018
270502
3rd Quarter TSC inventory Issues
08/08/2019
271572
3rd Quarter EP Mazon Relocation Center Inventory Issues
08/09/2019
04327348
Field Team Inventory 1Q2020 Items
03/17/2020
Miscellaneous
4th Quarter 2019 Call-In Augmentation Drill Results
2/17/2019
3rd Quarter 2019 Call-In Augmentation Drill Results
09/16/2019
4th Quarter 2018 Call-In Augmentation Drill Results
2/03/2018
Dresden 2018 Drive-In and Off Hours Drill Evaluation Report
08/29/2018
Emergency Response Organization (ERO) - Emergency
Response Facility (ERF) Activation and Operation
Corrective Action
Documents
DR-EP-2019-PEX-MCR-FAILED-DCS
06/25/2019
DR-EP-2019-PEX-TSC-FAILED-DCS
06/25/2019
DR-EP-2019-PEX-OSC-FAILED-DCS
06/25/2019
DR-EP-2019-NRC-MCR-FAILED-DCS
07/30/2019
DR-EP-2019-NRC-TSC-FAILED-DCS
07/30/2019
DR-EP-2019-NRC-OSC-FAILED-DCS
07/30/2019
Documentation of Completing hh2/155b Requirement
2/11/2020
Miscellaneous
Dresden Letters of Agreement Annual Review List 2019
Standardized Radiological Emergency Plan
Radiologicaly Emergency Plan Annex For Dresden Station
Self-Assessments NOSA-DRE-18-
Emergency Preparedness Audit Report for Dresden Station
04/18/2018
NOSA-DRE-19-
Emergency Preparedness Audit Report for Dresden Station
04/24/2019
Calibration
Records
DTS-7500-07
Standby Gas Treatment System Air Filter Unit Performance
Requirements (Methyl Iodide Removal and Charcoal Leak
Test
04/23/2018
MSA Posi3
- L04480
Posi3 USB Test Results; Facepiece/Airline Apparatus Test
06/062019
MSA SCBA FireHawk Monthly Inspection list
11/06/2019
Corrective Action
Documents
Unexpected Condition during SCBA Air Compressor
Preventive Maintenance
2/13/2019
Precautionary Measure for SCBA Bottle from Surveillance
05/02/2019
Drawings
M-49 Critical
Control Room
Drawing
Diagram of Standby Gas Treatment (SBGT)
Miscellaneous
NCS Corporation
- 0040599
Radioiodine Penetration/Efficiency Test Records SBGT
03/20/2019
PSI #00473572
Quarterly Service Air and Self-Contained Breathing
Apparatus
10/25/2019
Respiratory Inspection and Certification Log (Monthly
Inspection)
2/04/2019
Calculations
Intake Investigation Form #4513
11/07/2019
Intake Investigation Form #9316
01/09/2019
Intake Investigation Form #023119
01/09/2019
Intake Investigation Form # 040479
01/09/2019
Calibration
Records
NVLAP Lab
Code: 100518
NVLAP Certificate of Accreditation; Landauer, Inc
01/01/2020
Miscellaneous
Declaration of Pregnancy Form #SEGAT6114
09/17/2019
Declaration of Pregnancy Form #027354
03/27/2019
Corrective Action
Documents
Resulting from
Inspection
4317754
NRC ID: Cables Running Into Plant by U3 Trackway
2/13/2020
Corrective Action
Documents
280928
2/20/2020
290427
Historical Operability Review for DPIS 3-0261-35C
10/23/2019
04326046
Security - Loss of Power Affects EWS Zones/Cameras
03/12/2020
Corrective Action
Documents
Resulting from
Inspection
04319675
The NRC Resident Question of LER -2019-001-00
03/21/2020
Procedures
DOA 0040-03
Loss of Power to Non-Power Block Buildings
18